TAC dental fee schedule review
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1 TAC dental fee schedule review Submission to the Transport Accident Commission by Australian Dental Association Victorian Branch Inc.
2 ADAVB SUBMISSION RE TAC DENTAL SCHEDULE REVIEW INTRODUCTION The Australian Dental Association Victorian Branch Inc. (ADAVB) welcomes the invitation to provide input to the Transport Accident Commission s (TAC) review of its Dental Fee Schedule. The ADAVB is the professional association of dentists in Victoria, and its key objectives are to promote the improvement of the dental health of the public, the art and science of dentistry, and the highest standards of professional dental care. The ADAVB notes that: TAC patients are different to those who qualify for treatment under Department of Veterans Affairs entitlements, and as a consequence, an attenuated process is involved. Hence the examination, report to TAC, approval to proceed with treatment, provision of treatment, lodgment of the claim for payment for treatment provided and processing of that claim, take longer than DVA processes. The TAC dental fee schedule was last updated with effect from July The last time the ADAVB was invited to provide input to a fee review was in late TAC funding for dental services constitutes a relatively small element in the TAC s medical services budget, and most of those services are complex reconstructive and restorative services, frequently provided by specialists such as oral and maxillofacial surgeons and prosthodontists. The TAC Schedule and Dental Services policy may allow providers of dental care to require a copayment for the treatment they provide. If so, many dentists are unaware of this. Members report that payment processing by the TAC is slower than any other third party funder of dental treatment. DVA usually pays within 2 weeks of a treatment claim being lodged whereas instances have been reported of TAC claims taking up to 5 months. This lengthy delay in payment acts as a significant disincentive to dentists assisting TAC patients. The TAC Schedule in some instances uses definitions different to those contained in the ADA Schedule 8 th Edition, thus creating potential for confusion and errors. INCONSISTENT SCHEDULES While most treatment items in the TAC dental fee schedule align with the 8 th edition of The Australian Schedule of Dental Services and Glossary, published by the ADA in 2004, a number of items have been varied by TAC, resulting in potential confusion and inefficiency. It is vitally important that all dentists in Australia adhere to a common and reliable system by which to describe the treatments they provide. Consistency in dental records is one of the key dimensions of quality assurance, and as the key dental standards body in Australia, the ADA urges all dentists to comply with this fundamental standard.
3 ADAVB Submission re TAC Dental Fee Schedule Page 2 There are numerous third parties involved in funding of dental services, and if one is permitted to create its own version of the Schedule then all of them may feel that they are entitled to do so. TAC s decision to create a version of the Schedule that includes amendments to the ADA Schedule undermines the common national standards that Government agencies such as the Australian Commission on Safety and Quality in Healthcare Standards recommend. Another outcome of TAC using variations on the ADA Schedule is that it leads to confusion amongst dentists and can therefore lead to errors with possible medico-legal consequences. ADAVB therefore recommends that TAC confer with its clinical advisors to bring its schedule back into alignment with the ADA Schedule. RATE COMPARISONS The attached comparative table highlights the relative positions of the Mean ADAVB Surveyed Fees (July 2006 data), and TAC rates as at 1 July It must be noted that the survey data is historical, and that current fee rates will have moved on from this level since the data was collected, whilst the TAC rates are prospective, and apply until reviewed again at some future date. This means that the gap between the normal dental fees and the rates paid by the TAC is actually wider than is shown in the table. Whilst TAC rates are more generous in Prosthodontics areas such as crown and bridge, (which is not surprisingly a dominant response to road trauma), when a wider range of treatments is assessed it becomes obvious that the TAC rates are out of touch with the costs of delivering dental care. The Department of Veterans Affairs Fee Schedule, which is considered to contain concessional rates, was updated in November 2006, and yet most items are rebated at a higher level than the TAC dental fee schedule: A recent Access Economics study, commissioned by the ADA, concluded that the cost of regulatory compliance in Australian dental practices is averaging $64,000 pa. per practitioner. This validated feedback to the ADAVB from its members expressing concerns at the ever increasing cost of regulatory compliance, and the need to formally address this factor in setting fee levels: The impact of these growing costs on dentist participation in Government sponsored schemes is the same for VWA and TAC as indicated by the ADA Inc regarding the DVA scheme. If dentists do not cover their costs then they withdraw their services to be able to focus on providing treatment to patients who can pay rates which align with real expense ratios. Given the evident shortage of dentists in Australia, there is no shortage of such patients, especially in regional and rural areas. It is a relatively simple decision for dentists therefore to choose to treat patients who cover their costs rather than those that require the practice to subsidise their care from the dentist s pocket.
4 ADAVB Submission re TAC Dental Fee Schedule Page 3 Members have reported that current TAC fee rates have ceased to provide a reasonable return on their time and effort, and indeed in some cases, do not even cover overheads. One member expressed it as follows: Recent cases that I have done are at fees 30% below Vet Affairs rates. It is impossible to provide for cases that involve a lab fee not that much different to the TAC fee. A loss situation has left me with no option but to remove my services to TAC patients until the fees increase to a reasonable level. The attached comparative graphs and table (*) reveal rates that: differ widely, with some TAC rates being as much as 76% below the surveyed fees, and many being over 20% below. Most TAC fees are also lower that the concessional rates paid for dental treatment by DVA. offer general practitioner dentists virtually no margin on prosthodontic treatments many of them would be well qualified to provide, thus causing referral to specialists at costs to the TAC much greater than need be the case. Generally speaking, referral to a specialist should only be required where the complexity of the work is beyond that a GP is capable of handling. This would be the case with many trauma victims, but not all. have inconsistent differentials paid for specialist services. Negative figures of 20% or more in the comparison of TAC Specialists rates compared with ADAVB GP rates indicate acceptable fee differentials, whilst positive figures indicate that the TAC is paying specialists below the rate normally charged by GP dentists. Specialist fees around 20% - 25% higher than GP fees are supported by the ADAVB. * Note: Only item numbers from the TAC schedule that matched current definitions in the ADA Schedule were able to be used in the comparative graphs and table. As TAC has modified some item numbers this made certain comparisons invalid, thus illustrating the problem described above. RECOMMENDATIONS To address these problems the ADAVB recommends: 1. The current level of TAC fees be increased to a level commensurate with the mean level of fees, as reflected in the 2006 ADA Inc. dental fee survey but with appropriate CPI adjustments from the date of the last survey. 2. That TAC dental fees be indexed in line with medical services. 3. That the TAC dental fee schedule be amended to achieve consistency with the ADA Schedule 8 th edition. 4. That TAC modify its advice to dental care providers to make it clear that co-payments can be accepted from TAC patients. 5. That TAC review its business processes to ensure that claims are dealt with more expeditiously.
5 ADAVB Submission re TAC Dental Fee Schedule Page 4 ATTACHMENT: Comparisons of TAC fees and ADA Surveyed Fees as at 1 July 2006 TAC - ADA Comparison 100 Preventive Services Fee Item Number TAC GP July 2006 $ ADA GP Mean 2006 $ TAC - ADA Comparison 300 Oral Surgery Fee Item NUmber TAC GP July 2006 $ ADA GP Mean 2006 $ TAC - ADAVB Comparison 400 Endodontics Fee * 455 TAC GP July 2006 $ ADAVB GP Mean 2006 $ Item Number
6 ADAVB Submission re TAC Dental Fee Schedule Page 5 TAC - ADA Comparison 500 Restorative Services Fee Item Number TAC GP July 2006 $ ADA GP Mean 2006 $ TAC - ADA Comparison 600 Crown and Bridge Fee TAC GP July 2006 $ ADA GP Mean 2006 $ Item Number TAC - ADAVB Comparison 700 Prosthodontics Fee TAC GP July 2006 $ ADA GP Mean 2006 $ Item Number
7 ADAVB Submission re TAC Dental Fee Schedule Page 6 TAC - ADA Comparison 900 General Services Fee Item Number TAC GP July 2006 $ ADA GP Mean 2006 $
8 ADAVB Submission re TAC Dental Fee Schedule Page 7 TAC GP ADAVB GP TAC vs ADAVB DVA GP TAC vs DVA July 2006 Mean 2006 % Difference Nov 2006 % Difference $ $ $ 011 Comprehensive oral exam. N/A N/A N/A 011, 018 Initial examination and completion of TAC report form "DTF 1" N/A N/A N/A N/A 012 Periodic oral exam % % 013 Oral examination - limited N/A N/A N/A 014 Consultation N/A N/A S Only N/A Consultation arranged by the TAC for a second opinion, including a 014, 018 written report N/A N/A N/A N/A 018 Comprehensive clinical report (not elsewhere included) N/A N/A N/A N/A 022 Intraoral, periapical or bitewing - per film % % 025 Intraoral radiograph - occlusal, maxillary or mandibular - per exposure N/A N/A N/A N/A 031 Extraoral radiograph - maxillary, mandibular - per exposure N/A N/A N/A N/A 036 Cephalometric radiograph N/A N/A S Only N/A 037 Panoramic radiograph % % 039 Tomography of the skull or parts thereof N/A N/A N/A N/A 047 Caries activity screening test N/A N/A N/A N/A 051 Biopsy of tissue N/A N/A N/A N/A 061 Pulp vitality testing - per visit (max 3 visits per year) N/A N/A N/A N/A 071 Diagnostic model % % 072 Photographic records - intraoral % FBN N/A 111 Removal of plaque and/or stain N/A N/A N/A 113 Recontouring pre-existing restoration(s) N/A N/A N/A N/A 114 Removal of plaque and/or stain % % 115 Removal of calculus - subsequent visit N/A N/A N/A N/A 117 Non-vital bleaching (if separate appointments are made) N/A N/A FBN N/A 118 Bleaching, internal - per tooth N/A N/A N/A N/A
9 ADAVB Submission re TAC Dental Fee Schedule Page 8 TAC GP ADAVB GP TAC vs ADAVB DVA GP TAC vs DVA July 2006 Mean 2006 % Difference Nov 2006 % Difference $ $ $ 121 Topical application of remineralising agent % % 123 Concentrated remineralising agent, application - single tooth N/A N/A N/A N/A 131 Dietary advice N/A N/A N/A N/A 141 Oral hygiene instruction % % 151 Provision of a mouthguard - indirect N/A N/A N/A 161 Fissure sealing - per tooth N/A N/A N/A 165 Desensitisation of dentine (per visit) N/A N/A % 171 Odontoplasty for fractured teeth (per tooth) N/A N/A % 213 Treatment of acute periodontal infection - per visit N/A N/A N/A N/A 221 Clinical periodontal analysis and recording N/A N/A N/A N/A 222 Root planing and subgingival curettage - per 8 teeth or less FBN N/A N/A 225 Non-surgical periodontal treatment where not otherwise specified - per visit N/A N/A N/A N/A 232 Periodontal flap surgery - per 8 teeth or less FBN N/A FBN N/A 245 Periodontal surgery involving one tooth or an implant N/A N/A N/A N/A 282 Continuation/review of periodontal treatment or maintenance subsequent to item 281 N/A N/A N/A N/A 311 Removal of tooth or part(s) thereof % % 314 Sectional removal of tooth N/A N/A % 322 Surgical extraction without bone removal N/A N/A % 323 Surgical removal of a tooth or tooth fragment requiring removal of bone % % 331 Alveolectomy - per segment N/A N/A N/A N/A 337 Reduction of fibrous tuberosity N/A N/A N/A N/A 377 Removal of soft tissue N/A N/A % 378 Surgical removal of foreign body N/A N/A N/A N/A 384 Repositioning of displaced tooth/teeth - per tooth N/A N/A N/A N/A
10 ADAVB Submission re TAC Dental Fee Schedule Page 9 TAC GP ADAVB GP TAC vs ADAVB DVA GP TAC vs DVA July 2006 Mean 2006 % Difference Nov 2006 % Difference $ $ $ 386 Repositioning and splinting of displaced tooth N/A N/A % 387 Replantation and splinting of a tooth N/A N/A N/A N/A 387, 772 Replanting avulsed tooth and splinting N/A N/A N/A N/A 391 Frenectomy N/A N/A N/A N/A 392 Incision and drainage of abscess or cyst N/A N/A N/A N/A 411 Direct pulp capping % % 412 Incomplete endodontic therapy (inoperable or fractured) N/A N/A N/A N/A 414 Cvek pulpotomy N/A N/A % 415 Complete chemo-mechanical preparation of root canal - one canal % % 416 Complete chemo-mechanical preparation of root canal - each additional canal % % 417 Root canal obturation - one canal % % 418 Root canal obturation - each additional canal % % 419 * Extirpation of pulp or debridement of root canal(s) - emergency or palliative % % 432, 434 Apicectomy and apical seal N/A N/A FBN N/A 433 Exploratory periradicular surgery N/A N/A N/A N/A 445 Exploration for a calcified root canal - per canal N/A N/A N/A N/A 451 Removal of root filling (per canal) N/A N/A % 452 Removal of cemented root canal post or post crown N/A N/A N/A N/A 453 1Removal or bypassing fractured endodontic instrument N/A N/A N/A N/A 455 Additional visit for irrigation and/or dressing of the root canal system - per tooth % % 457 Obturation of resorption defect or perforation (non-surgical) N/A N/A N/A N/A 458 Interim therapeutic root filling - per tooth N/A N/A N/A N/A 511 Metallic restoration - one surface - direct % % 512 Metallic restoration - two surfaces - direct % %
11 ADAVB Submission re TAC Dental Fee Schedule Page 10 TAC GP ADAVB GP TAC vs ADAVB DVA GP TAC vs DVA July 2006 Mean 2006 % Difference Nov 2006 % Difference $ $ $ 513 Metallic restoration - three surfaces - direct % % 514 Metallic restoration - four surfaces - direct N/A N/A N/A 515 Metallic restoration - five surfaces - direct % % 521 Adhesive restoration - one surface - anterior tooth - direct % % 522 Adhesive restoration - two surfaces - anterior tooth - direct % % 523 Adhesive restoration - three surfaces - anterior tooth - direct % % 524 Adhesive restoration - four surfaces - anterior tooth - direct % % 525 Adhesive restoration - five surfaces - anterior tooth - direct N/A N/A N/A 531 Adhesive restoration - one surface - posterior tooth - direct % % 532 Adhesive restoration - two surfaces - posterior tooth - direct % % 533 Adhesive restoration - three surfaces - posterior tooth - direct % % 534 Adhesive restoration - four surfaces - posterior tooth - direct N/A N/A N/A 535 Adhesive restoration - five surfaces - posterior tooth - direct N/A N/A N/A 542 Metallic inlay or onlay - two surface cavity N/A N/A N/A N/A 543 Metallic inlay or onlay - three surface cavity N/A N/A N/A N/A 572 Temporary restoration emergency or interim treatment only N/A N/A % 574 Metal band N/A N/A N/A N/A 575 Pin retention - per pin % % 577 Cusp capping - per cusp N/A N/A N/A 578 Restoration of an incisal corner - per corner N/A N/A N/A 582 Veneer - direct % % 583 Veneer - indirect % FBN N/A 595 Removal of inlay/onlay N/A N/A N/A 85.6 N/A 596 Recementing of inlay/onlay N/A N/A N/A N/A
12 ADAVB Submission re TAC Dental Fee Schedule Page 11 TAC GP ADAVB GP TAC vs ADAVB DVA GP TAC vs DVA July 2006 Mean 2006 % Difference Nov 2006 % Difference $ $ $ 597 Post - direct preformed N/A N/A % 611 Full crown - acrylic resin - indirect N/A N/A N/A N/A 613 Indirect non-metallic full crown N/A N/A % 615 Full crown - veneered - indirect % % 618 Full crown - metallic - indirect % % 625 Cast core for crown including post N/A N/A % 627 Preliminary restoration for crown - direct % % 629 Post and root cap - indirect N/A N/A N/A N/A 631 Provisional crown N/A N/A N/A N/A 632 Temporary composite bridge when not part of definitive treatment (per pontic) N/A N/A FBN N/A 642 Pontics - direct N/A N/A FBN N/A 643 Bridge pontic - indirect - per pontic % FBN N/A 643 / 649 Bridge - indirect bonded (Maryland) - 1 pontic N/A N/A FBN N/A 643 / 649 Bridge - indirect bonded (Maryland) - 2 pontics N/A N/A FBN N/A 651 Recementing crown or veneer N/A N/A N/A 652 Recementing bridge or splint - per abutment N/A N/A N/A N/A 653 Rebonding of bridge or splint where retreatment of bridge surface is required N/A N/A N/A N/A 655 Removal of crown N/A N/A N/A N/A 656 Removal of bridge or splint N/A N/A N/A N/A 661 Fitting of implant abutment - per abutment N/A N/A N/A N/A 661, 672 Implant based veneered - full crown N/A N/A N/A N/A 666 Prosthesis with metal frame for bridgework (per implant) N/A N/A N/A N/A 669 Removal and reattachment of implant prosthesis for repair or cleaning N/A N/A N/A N/A 671 Full crown attached to osseointegrated implant - non metallic - indirect N/A N/A N/A N/A
13 ADAVB Submission re TAC Dental Fee Schedule Page 12 TAC GP ADAVB GP TAC vs ADAVB DVA GP TAC vs DVA July 2006 Mean 2006 % Difference Nov 2006 % Difference $ $ $ 672 Full crown attached to osseointegrated implant - veneered - indirect N/A N/A N/A 673 Full crown attached to osseointegrated implant - metallic - indirect N/A N/A N/A N/A 679 Surgical implant guide N/A N/A N/A N/A 688 Insertion of one-stage endosseous implant - per implant FBN N/A N/A N/A 711 Complete maxillary denture % % 712 Complete mandibular denture N/A N/A N/A N/A 719 Complete maxillary and mandibular dentures % % 721 Partial maxillary denture - resin base N/A N/A N/A N/A 721,722 Partial denture - acrylic base: one tooth N/A N/A N/A N/A 721, 722 Partial denture - acrylic base: two teeth N/A N/A N/A N/A 721, 722 Partial denture - acrylic base: three teeth N/A N/A N/A N/A 721, 722 Partial denture - acrylic base: four teeth N/A N/A N/A N/A 721, 722 Partial denture - acrylic base: five to nine teeth N/A N/A N/A N/A 721, 722 Partial denture - acrylic base: ten teeth or more N/A N/A N/A N/A 727 Partial maxillary denture - cast metal framework N/A N/A N/A N/A Partial denture - chrome cobalt including cost of casting: one ore two 727, 728 teeth N/A N/A N/A N/A Partial denture - chrome cobalt including cost of casting: three or four 727, 728 teeth N/A N/A N/A N/A Partial denture - chrome cobalt including cost of casting: five to nine 727, 728 teeth N/A N/A N/A N/A Partial denture - chrome cobalt including cost of casting: ten teeth or 727, 728 more N/A N/A N/A N/A 731 Each retainer N/A N/A % 732 Occlusal rest (not part of retainer) N/A N/A % 733 Tooth/teeth (partial denture) N/A N/A N/A N/A 736 Immediate tooth replacement 5.65 N/A N/A % 737 Resilient lining N/A N/A N/A N/A
14 ADAVB Submission re TAC Dental Fee Schedule Page 13 TAC GP ADAVB GP TAC vs ADAVB DVA GP TAC vs DVA July 2006 Mean 2006 % Difference Nov 2006 % Difference $ $ $ 738 Wrought bar N/A N/A N/A N/A 741 Adjustment of a denture N/A N/A N/A 743 Relining - complete denture - processed % % 744 Partial denture relining N/A N/A % 753 Cleaning and polishing of pre-existing denture N/A N/A N/A N/A 754 Denture base modification N/A N/A N/A N/A 761 Reattaching pre-existing tooth or clasp to denture N/A N/A N/A N/A 762 Replacing clasp on denture N/A N/A N/A N/A 763 Repairing broken base of a complete denture N/A N/A N/A 764 Repairing broken base of a partial denture N/A N/A N/A N/A 765 Replacing first tooth on denture N/A N/A N/A N/A 768 Adding tooth to partial denture to replace an extracted or decoronated tooth - per tooth % % 776 Impression - denture repair/modification N/A N/A N/A 821 Active removable appliance - per arch % FBN N/A 831 Full arch banding - per arch N/A N/A FBN N/A 911 Palliative care N/A N/A N/A 915 After hours callout N/A N/A N/A N/A 916 Travel to provide services N/A N/A N/A N/A 926 Individually made tray - medicament(s) N/A N/A N/A Full clinical assessment of case including joint and muscle palpation, 963, 964 occlusal analysis with study models and report to the TAC N/A N/A N/A N/A 965 Occlusal splint % % 966 Routine adjustment of splint - per visit (max of 6 visits) N/A N/A FBN N/A 981 Splinting and stabilisation - direct - per tooth N/A N/A N/A N/A 986 Post-operative care where not otherwise included N/A N/A N/A N/A * 419 For TAC procedure not exceeding 15 minutes
15 INFORMATION SUMMARY 2006/07 ABOUT THE ADAVB The ADAVB is the peak professional association of Victorian dentists and its aims are to improve the dental health of all Victorians; promote the art and science of dentistry; and promote the highest standards of professional dental care enhance the professional lives of members MEMBERSHIP About 2480 dentists in private and public practice, as well as 4 th & 5 th year students and overseas trained candidates 95% of registered private practitioners 10 suburban and 7 country groups MEMBER SERVICES & FUNCTIONS DISPUTE RESOLUTION SERVICES Continuing Professional Development Program Dental health education programs (eg. Dental Health Week) Community Relations dispute resolution Code of Ethics (Conduct) Recent Graduate support Dental Assistant Training seminars Member Service Plans (eg Professional Insurances; preferred suppliers) Industrial relations advice and representation Defence and legal support Advice on Practice Management Quality Assurance (including Doctors Health Support Service) Benevolent Fund Library and resource collection Political representation Representation to Government bodies Superannuation (Professional Provident Fund) Sports and social functions Publications Newsletter, Journal, Award details, Manuals etc. Home Page (find us at The Branch provides information to the public on dental matters, and offers a conciliation service to assist patients to resolve disputes with members. Information on treatments, facilities, dental issues and careers is available. PRESIDENT Dr Greg Morris BDSc, LDS Greg is a general practitioner in Hawthorn. He has served on numerous ADA committees including Dental Health Education, Graduate Education and Infection Control CHIEF EXECUTIVE OFFICER Mr Garry Pearson MEdSt, HDT (SAC) AFAIM, MAICD Garry commenced with the ADAVB in 1991 after senior executive roles in the Victorian Education Ministry AUSTRALIAN DENTAL ASSOCIATION VICTORIAN BRANCH INC. ABN Reg d Assoc. No.A E 49 MATHOURA ROAD (P.O.BOX 434) TOORAK 3142 TEL: (03) FAX: (03) adavbinfo@adavb.com.au
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